Pending injunction applications must be decided expeditiously, uninfluenced by interim status quo orders.

The petitioner instituted a suit seeking a declaration of ownership, possession and consequential reliefs concerning the suit property.

Along with the suit, he filed applications under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908 (CPC), seeking to restrain alienation or creation of third-party interests and alteration of the property’s nature.

The Trial Court issued summons but did not grant ex parte interim relief. The petitioner challenged that order, contending that the caveat had been lodged only against defendant No. 7.

On 27 April 2026, the High Court directed the parties to maintain status quo pending further hearing.

The matter came before the Court with defendant No. 7 served and the pleadings complete.

1. Whether the Trial Court’s issuance of summons and deferral of consideration of the interim applications, in light of the caveat, required interference by the High Court.

2. Whether the High Court should determine the challenge to its interim status quo order at that stage, or instead direct the Trial Court to decide the pending applications.

The petitioner’s interim applications were under Order XXXIX Rules 1 and 2 CPC, which provide for temporary injunctions in appropriate cases.

The petition invoked the High Court’s jurisdiction under Article 226 of the Constitution.

Although the parties relied on the effect of the caveat, the Court did not state or apply a substantive rule determining the caveat’s scope; it left that issue unexamined at this stage.

The Court noted that the suit summons had been issued and that defendant No. 7 had been served, with pleadings complete. It therefore found no impediment to the Trial Court considering and deciding the pending injunction applications.

Rather than deciding whether the caveat justified the Trial Court’s course or examining the challenge concerning the High Court’s status quo order, the Court considered it sufficient to require a prompt decision on the applications.

It directed that the Trial Court decide them independently, without being influenced by the High Court’s interim order or the order’s findings.

The High Court’s status quo order dated 27 April 2026 was to continue until the applications were considered, but the Trial Court was not to be influenced by that order or by any findings in the High Court’s order.